Application/Control Number: 95/002,035 and 90/012,342
`Art Unit: 3992
`
`Page 25
`
`the specification, limitations from the specification are not read into the claims. See In re Van
`
`Geuns, 988 F.2d 1181, 26 USPQ2d 1057 (Fed. Cir. 1993).
`
`In resp'onse to Patent owner arguments against the references individually, .one cannot
`
`show nonobviousness by attacking references individually where the rejections are based on
`
`combinations of references. See In re Keller, 642 F.2d 413,208 USPQ 871 (CCPA 1981);,In re
`
`Merck & Co., 800 F.2d 1091, 231 USPQ 375 (Fed. Cir. 1986). Willens teaches a redirection
`
`server (communications server) that receives user's filter for controlling access by the user to
`
`Internet sits (5: 17-18). The reference teaches permitting or denying access to network resources
`
`(6:6) and applying the user's associated filter by allowing or blocking packets (6:10-15). The
`
`Admitted Prior Art teaches controlling access to resources by redirecting traffic (' 118 Patent
`
`1 :38-60). It would have been obvious to incorporate the redirection technique of the Admitted
`
`Prior Art into the system of Willens for the reasons expressed in Exhibit AA (see at least page
`
`56).
`
`Regarding claim 27, the Examiner agrees with Patent owner that Willens does not teach
`
`removal or reinstatement of at least a portion of the rule set as function of one or more of: time,
`
`the data transmitted to or from the user or locations the user accesses. Willens discloses
`
`modifying the list of sites a user is permitted to access. The reference states that "the subsystem
`
`12 provides a central, sever based permit list that can be easily updated on a daily or hourly
`
`basis." Also, "Willens teaches modifying a user's filtering rules based on a user's accessing of a
`
`login location and providing login information, such as password." See page 21 of Exhibit AA.
`
`Although Willens teaches updating the permit list,. the update does not necessarily
`
`include "removal or reinstatement" of a portion of the rule set. The process of updating requires
`
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`Application/Control Number: 95/002,035 and 90/012,342
`Art Unit: 3992
`
`Page 26
`
`making information current; thus, the action of deleting or restoring data is not compulsory.
`
`That is, updating could include inserting new data. Willens does not expressly define updating
`
`as reinstating data or removing data. Therefore, this rejection is withdrawn.
`
`Reiection of Claims 6, 7. 13. 14, 16-24, 26-44. 49-56. and 61-90 under 35 U.S.C. 103(a) over
`
`Radia in view of Wong '726 and further in view of Stockwell
`
`Radia 5,848,233; Wong 5,835,727; Wong 6,073,178
`
`PO: Patentee argues that these rejections should be withdrawn for the same reasons cited in
`
`Sections V and VI of the response.
`
`Patent owner asserts that nothing in Radia suggests or teaches nor is there any motivation
`
`to change a configuration of a router or modem during a session. Also, the reconfiguration·
`
`would have to be done by the ANCS, not the router itself as required by the '118 patent.
`
`TPR: See Requesters comments regarding Sections V and VI at pages 8-23 above.
`
`The Requester does not provide any comments regarding Patent owner's arguments that
`
`Radia does not teach or suggests nor is there any motivation to change a configuration of a router
`
`or modem during a session. Also, no comments are provided with regards to the ANCS
`
`performing reconfiguration not the router.
`
`Examiner: See the Examiner's comments regarding Sections V and VI at pages 8-23 above.
`
`The Examiner respectfully disagrees with Patent owner. As per the comment that
`
`"nothing in Radia suggest or teaches nor is there any motivation to change a configuration of a
`
`router or modem during a session," the Examiner notes that claims 16-24, 26-43, and 68-90
`
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`Application/Control Number: 95/002,035 and 90/012,342
`Art Unit: 3992
`
`Page 27
`
`recite modifying the rule set. Radia teaches changing filtering rules when a user is connected to
`
`a client system, logged into the system or logged out. See col. 3, lines 29-55. The reference
`
`states that when the user is successfully logged in, a filtering profile sequence is selected or
`
`generated then downloaded by the SMS to the ANCS. "The ANCS uses the rules included in the
`
`downloaded login filtering profile sequence to establish a new packet filter for IP packets
`
`originating from the newly logged in client system. The new packet filter is established by
`
`reconfiguring the components of the network to replace the packet filter established for the login
`
`filtering profile." Therefore, the new packet filter is created during a user session.
`
`Patentee also argues that "the reconfiguration would have to be done by the ANCS, not
`
`the router itself as required by the '118 patent." However, '118 patent states that "the redirection
`
`server is configured to allow modification .. ," In response to Patent owner argument that the
`
`references fail to show certain features of the invention, it is noted that the features upon which
`
`Patent owner relies (i.e., the router itself is required to do the reconfiguration) are not recited in
`
`the rejected claim(s). Although the claims are interpreted in light of the specification, limitations
`
`from the specification are not read into the claims. See In re Van Geuns, 988 F.2d 1181, 26
`
`USPQ2d 1057 (Fed. Cir. 1993). Also note that the Office action relies on the ANCS together
`
`with the router of Radia to teach the redirection server. See page 6 of Exhibit BB.
`
`RuleSet-Radia, Wong '727and Wong '178
`
`PO: Patent owner argues that a rule set defined by the '118 patent includes "allow" and "deny"
`
`and "redirect" actions on the data packets from the user computer, and "element or conditions"
`
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`Application/Control Number: 95/002,035 and 90/012,342
`Art Unit: 3992
`
`Page 28
`
`that need not be related to the header data of the data packet itself but that may instead relate to
`
`factors other than the packet data.
`
`Patent owner asserts that The Examiner has given no rationale as to how these references,
`
`alone or in any combination, would result in even an approximation of a redirection server with a
`
`programmed rule set as claimed in the ' 118 patent.
`
`Lastly, Patentee notes that the absence of any interaction between the router and the
`
`ANCS while the router is processing data packets from the user and the absence of any
`
`interaction between the router and the ANCS while the packet filter is being created by the
`
`ANCS, preclude viewing the combination of the two as a redirection server.
`
`TPR: The Requester argues that the '118 patent does not support Patent owner's definition of
`
`rule set.
`
`Regarding "elements or conditions" argument, Requester states that this proposed
`
`interpretation of rule set is inconsistent with the broadest reasonable interpretation of the claims
`
`in view of the '1 18 specification.
`
`As for the argument that Radia's ANCS and router cannot together constitute the claimed
`
`"redirection server", the Requester asserts that Patent owner has not provided any citation to the
`
`MPEP or any other legal authority in support of this argument. Also, the Requester states that
`
`Patent owner has taken the position in litigation that the redirection server may comprise
`
`multiple separate components. (See Request Ex. D2 at 18 ("In the alternative, the redirection
`
`server can be combination of the SSG and SESM.").
`
`Examiner: The Examiner agrees with the Requester.
`
`The specification describes the rule sets at col. 4, lines 41-49 as follows:
`
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`Application/Control Number: 95/002,035 and 90/012,342
`Art Unit: 3992
`
`Page 29
`
`The rule sets specify elements or conditions about the user's session. Rule sets may
`
`contain data about a type of service which may or may not be accessed, a location, which
`
`may or may not be accessed, how long to keep the rule set active, under what condition
`
`the rule set should be removed, when and how to modify the rule set during a session.
`
`During reexamination, claims are given the broadest reasonable interpretation consistent
`
`with the specification and limitations in the specification are not read into the claims (In re
`
`Yamamoto, 740 F.2d 1569, 222 USPQ 934 (Fed. Cir. 1984)).
`
`The router along with the ANCS functions as the redirection server. In Radia, the profile
`
`filtering database can be stored at ANCS. The ANCS utilizes the filtering profiles to reconfigure
`
`the router, which uses the filtering rules to selectively discard or forward IP packets received
`
`from the client systems (see at least abstract and claim 11 of Radia). Thus, the ANCS and the
`
`router together teach the redirection server.
`
`Modification of Rule Set by Redirection Server During Session - Reiected Claims 16-24. 26-
`
`29. 33-34, 36-43. 64, and 68-90
`
`PO: Patent owner argues that Radia does not teach, suggest or provide any motivation for
`
`modifying a rule during a user session, that is, after the rule set has been programmed into the
`
`redirection server for processing data packet from the user computer to the network. Also,
`
`Patentee asserts that Radia does not teach modifying the packet filter by the redirection server. It
`
`is noted that there is no teaching in Radia (or any of the other references) that the router or
`
`modem itself reconfigures or modifies the downloaded packet filter once that packet filter has
`
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`Application/Control Number: 95/002,035 and 90/012,342
`Art Unit: 3992
`
`Page 30
`
`been programmed into router/modem, or that a rule set include elements or conditions that
`
`enable the router to change the rule set during a session.
`
`TPR: Requester submits that the claims do not require the redirection server itself to modify the
`
`rule set. Claim 16 recites the redirection server is configured to allow modification of at least a
`
`portion of a rule set. Claim 83 recites a method that includes modifying step, but does not recite
`
`who or what must perform that step.
`
`Requester notes that Patent owner's argued claim interpretation is inconsistent with the
`
`broadest reasonable interpretation in light of the specification. Regarding Patent owner's
`
`comments that there is no teaching whatever in Radia ... that the router and modem itself
`
`reconfigures or modifies the downloaded packet filter once that packet filter has been
`
`programmed into the router/modem, Requester states that the Examiner's rejection provided
`
`substantial analysis of Radia's teachings with respect to modifying a user's rule set.
`
`Examiner: The specification describes the rule sets at col. 4, lines 41-49 as follows:
`
`The rule sets specify elements or conditions about the user's session. Rule sets may
`
`contain data about a type of service which may or may not be accessed, _a location, which
`
`may or may not be accessed, how long to keep the rule set active, under what condition
`
`the rule set should be removed, when and how to modify the rule set during a session.
`
`During reexamination, claims are given the broadest reasonable interpretation consistent
`
`with the specification and limitations in the specification are not read into the claims (In re
`
`Yamamoto, 740 F.2d 1569, 222 USPQ 934 (Fed. Cir. 1984)). However, column four's
`
`description of rule set does not limit the rule set to modification during a session. Instead, it is
`
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`Application/Control Number: 95/002,035 and 90/012,342
`Art Unit: 3992
`
`Page 31
`
`states that the rule set may contain information about "wheIJ. and how to modify the rule set
`
`during a session, but is not limited to this function.
`
`Reiection -Reiected Claims 31, 35, 61, 66, and 67
`
`PO: Patent owner argues that Radia does not teach, suggest nor provide any motivation for
`
`redirection as an action in the event of a match. Also, the queries of Stockwell do not occur
`
`during a session but only at the start of the session. Finally, the rejected claims are dependent
`
`from claims previously discussed as being allowable over the cited references, alone or in any
`
`possible combination, and fpr the same reasons presented for those claims, the rejections of
`
`claims 31, 35, 61, 66-67 should also be withdrawn.
`
`TPR: Requester notes that "One cannot show nonobviousness by attacking references
`
`individually where the rejections are based on combinations of references." Also, it is noted that
`
`proposed rejections provided reasons to combine Radia and Stockwell with particular focus on
`
`incorporating Stockwell's redirection feature into Radia's overall system.
`
`Examiner: The Examiner agrees with the Requester. The Office Action provided reasons for
`
`combining Radia and Stockwell.
`
`In response to Patent owner arguments against the references individually, one cannot
`
`show nonobviousness by attacking references individually where the rejections are based on
`
`combinations ofreferences. See In re Keller, 642 F.2d 413,208 USPQ 871 (CCPA 1981); In re
`
`Merck & Co., 800 F.2d 1091, 231 USPQ 375 (Fed. Cir. 1986).
`
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`Page 497 of 1408
`
`

`

`Application/Control Number: 95/002,035 and 90/012,342
`Art Unit: 3992
`
`Page 32
`
`Rejection of Claims 2-5, 9-12, 45-48 and 57-60 under 35 U.S.C. 103(a) over Radia in view of
`
`Wong'726 and Stockwell and further in view of Wong '178
`
`PO: Patent owner states that the rejection of the above claims should be withdrawn for the same
`
`reasons as set forth in Sections V-VII of the response.
`
`TPR: Requester states that the Examiner's rejections are proper and should be made final.
`
`Examiner: The Examiner respectfully disagrees with patent owner for reasons indicated above.
`
`Rejection of Claims 7, 14, 16-24, 50-56 and 62-90 under 35 U.S. C. 103(a) over Radia in view
`
`of Wong '726 and further in view of Admitted Prior Art
`
`PO: Patent owner states that the. rejection of the above claims should be withdrawn for the same
`
`reasons as set forth in Sections V -VII of the response.
`
`TPR: Requester states that the Examiner's rejections are proper and should be made final.
`
`Examiner: The Examiner respectfully disagrees with patent owner for reasons indicated above.
`
`Rejection of Claims 2-5, 9-12. 45-48 and 57-60 under 35 U.S. C. 103(a) over Radia in view of
`
`Wong '726 and further in view of Admitted Prior Art in view of Wong '178
`
`PO: Patent owner states that the rejection of the above claims should be withdrawn for the same
`
`reasons as set forth in Sections V -VII of the response.
`
`TPR: Requester states that the Examiner's rejections are proper and should be made final.
`
`Examiner: The Examiner respectfully disagrees with patent owner for reasons indicated above.
`
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`Application/Control Number: 95/002,035 and 90/012,342
`Art Unit: 3992
`
`Page 33
`
`Reiection of Claims 2-71 9-14.16-241 26-54, 60-66, 68-81 and 83-89 under 35 U.S.C. 103(a)
`
`over He, Zenchelsky and Admitted Prior Art
`
`Reiection of Claims 2-7, 9-14. 16-24, 26-541 60-66. 68-81 and 8-89 under 35 U.S.C. 103(a)
`
`over He, Zencltelsky, Fortinsky and Admitted Prior Art
`.
`--
`PO: Patent owner argues that the no reasonable likelihood of success with respect to the above
`claims has been shown and the decision to even grant the present Reexamination should be
`
`withdrawn and such action is courteously requested.
`
`TPR: Requester notes that new analysis was applied in rejecting the claims not previously
`
`considered by the Patent Office of Zenchelsky's teachings and Fortinsky is new prior art. Also,
`
`decision to order reexamination is not subject to review by petition or otherwise. MPEP 2646
`
`(II).
`
`Examiner: The Examiner agrees with the Requester.
`
`Claims 2-7. 9-14, 16-24, 26-64, 60-66. 68-81 and 83-89
`
`PO: Patent owner argues that none of the references, alone or in any possible combination,
`
`teach, suggest or provide any motivation for a redirection server to control access to the network
`
`itself. Also, Patentee submits that the references do not teach or suggest a redirection server
`
`between the user and the network that is programmed with a "rule set" that includes "elements or
`
`conditions" which can change during a user session to enable the redirection server to modify the
`
`rule set during a user session according to .the programmed rule set.
`
`TPR: The Requester asserts that the claims do not recite controlling access to the network itself.
`
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`Page 499 of 1408
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`

`

`Application/Control Number: 95/002,035 and 90/012,342
`Art Unit: 3992
`
`Page 34
`
`Examiner: Regarding claims 2-7, 9-14, 28-35, 44-54, and 60-66, the Examiner respectfully
`
`disagrees with Patent owner. These do not recite modifying the rule set during a session. Patent
`
`'118 recites "the rule sets specify elements or conditions about the user's session. Rule sets may
`
`contain data about a type of service which may or may not be accessed ... when and how to
`
`modify the rule set during a session and the like." See col. 4, lines 41-4 7. Hence, it is not always
`
`a requirement for the rule se.t to always contain information regarding how and when to modify
`
`the rule set during a session.
`
`Additionally, in response to Patent owner argument that the references fail to show
`
`certain features of the invention, it is noted that the features upon which Patent owner relies (i.e.
`
`redirection server to control access to the network itself and redirection server between the user
`
`and the network) are not recited in the rejected claim(s). Although the claims are interpreted in
`
`light of the specification, limitations from the specification are not read into the claims. See In
`
`re Van Geuns, 988 F.2d 1181, 26 USPQ2d 1057 (Fed. Cir. 1993).
`
`However, as per claims 16-24, 26, 27, 36-39, 68-82, 84, and 85, the rejection of these
`
`claims are withdrawn for the following reasons.
`
`Claims 16-23 recite "wherein the redirection server is configured to allow automated
`
`modification of at least a portion of the rule set as a function of some combination of time, data
`
`transmitted to or from the user, or location the user access". The rejection relied upon the Board
`
`decision which stated that "blocking a website based on these bases would have been obvious"
`
`(Board decision at 10) and also on He for teaching this feature. Upon further review, the
`
`Examiner notes that He's authentication lifetime does not teach the time condition. "He does
`
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`Application/Control Number: 95/002,035 and 90/012,342
`Art Unit: 3992
`
`Page 35
`
`not, however, draw a connection between the authentication lifetime and the administrator's use
`
`of the database tool." (Board decision page 7).
`
`Additionally, the statement from the Board decision that "blocking a website based on
`
`these bases would have been obvious" is referring to redirecting data and not to modifying the
`
`rule set as recited in the claims. See Board decision, pages 8 and 9.
`
`Regarding claims 40-42, in response to Patent owner argument that the references fail to
`
`show certain features of the invention, it is noted that the features upon which Patent owner
`
`relies (i.e. redirection server to control access to the network itself and redirection server between
`
`the user and the network) are not recited in the rejected claim(s). Although the claims are
`
`interpreted in light of the specification, limitations from the specification are not read into the
`
`claims. See In re Van Geuns, 988 F.2d 1181, 26 USPQ2d 1057 (Fed. Cir. 1993).
`
`As per claim 83 and 86-90, in response to Patent owner argument that the references fail
`
`to show certain features of the invention, it is noted that the features upon which Patent owner
`
`relies (i.e. redirection server to control access to the network itself) are not recited in the rejected
`
`claim(s). Although the claims are interpreted in light of the specification, limitations from the
`
`specification are not read into the claims. See In re Van Geuns, 988 F.2d 1181, 26
`
`USPQ2d 1057 (Fed. Cir. 1993). Also, as per the limitation, "a redirection server connected
`
`between a user computer and a public network," Zenchelsky discloses this feature at Fig. 4.
`
`Note. The filter is between the Internet and user.
`
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`Application/Control Number: 95/002,035 and 90/012,342
`Art Unit: 3992
`
`Page 36
`
`FIG. 4
`(PRIOR ART)
`
`44
`
`41
`
`45
`
`Rule Set
`
`As per Patent owner's arguments regarding the rule set, during reexamination, claims are
`
`given the broadest reasonable interpretation consistent with the specification and limitations in
`
`the specification are not read into the claims (In re Yamamoto, 740 F.2d 1569, 222 USPQ 934
`
`(Fed. Cir. 1984)).
`
`Radia in view of Admitted Prior Art and further in view of Coss
`
`Redirection according to rule set programmed in the redirection server
`
`Patent owner argues that Radia does not mention redirection and does not suggest any
`
`reason why redirection would be beneficial in accomplishing the goal of Radia. Similarly, Coss
`
`mentions redirection but only as a means to unburden the firewall. See Coss at 2:45. The
`
`purpose of "unburdening the firewall" is wholly unrelated to and not suggestive ofredirection for
`
`purposes of controlling access to a network itself.
`
`During reexamination, claims are given the broadest reasonable interpretation consistent
`
`with the specification and limitations in the specification are not read into the claims (In re
`
`Yamamoto, 740 F.2d 1569, 222 USPQ 934 (Fed. Cir. 1984)).
`
`Panasonic-1012
`Page 502 of 1408
`
`

`

`Application/Control Number: 95/002,035 and 90/012,342
`Art Unit: 3992
`
`Page 37
`
`In response to Patent owner argument that the references fail to show certain features of
`
`the invention, it is noted that the features upon which Patent owner relies (i.e., redirection for
`
`purposes of controlling access to a network itself) are not recited in the rejected claim(s).
`
`Although the claims are interpreted in light of the specification, limitations from the specification
`
`are not read into the claims. See In re Van Geuns, 988 F.2d 1181, 26 USPQ2d 1057 (Fed. Cir.
`
`1993).
`
`Modification of a Portion o(the Rule Set During a Session
`
`Patent owner argues that the requirement of modification of the rule set during a user
`
`session is an explicit aspect of the definition of "rule set" in the '118 patent, and none of the cited
`
`references, either singly or in any possible combination, teach, suggest or provide any motivation
`
`for modification of a rule set by a redirection server during a user session after the rule set has
`
`been programmed into the redirection server and while the temporary network address is
`
`assigned.·
`
`As per claims 2-7, 9-14, and 44-67, the Examiner respectfully disagrees with Patent
`
`owner that modifying the rule set during a session is a requirement of the claims. Patent '118
`
`recites "the rule sets specify elements or conditions about the user's session. Rule sets may
`
`contain data about a type of service which may or may not be accessed ... when and how to
`
`modify the rule set during a session and the like." See col. 4, lines 41-47. Hence, it is not always
`
`a requirement for the rule set to always contain information regarding how and when to modify
`
`the rule set during a session. Also, these claims do not recite modifying the rule set during the
`
`user session. Although the claims are int.erpreted in light of the specification, limitations from
`
`Panasonic-1012
`Page 503 of 1408
`
`

`

`Application/Control Number: 95/002,035 and 90/012,342
`Art Unit: 3992
`
`Page 38 .
`
`the specification are not read into the claims. See In re Van Geuns, 988 F.2d 1181, 26
`
`USPQ2d 1057 (Fed. Cir. 1993).
`
`As per claims 16-24, 26-43, and 68-90, modification of the rule set is required, which is
`
`taught by Coss. The claims recite "wherein the redirection server is configured to allow
`
`automated modification of at least a portion of the rule set correlated to the temporarily assigned
`
`network address." Coss teaches dynamic rules are rules which are included with the access rules
`
`as a need arises. These rules can be loaded at any time to authorize specific network sessions.
`
`The dynamic rules allow a given rule set to be modified based on events happening in the
`
`network. See col. 8, lines 24-36. Hence, the rule set, which can be used to authorized network
`
`sessions, can be modified.
`
`Patent owner argues that in Radia, the static filter created by the ANCS and used to
`
`configure the router is not the same as the individuali~ed rule set with elements or conditions that
`
`can change the rule set during a user session and that the filter configuration in the router of
`
`Radia is static· through a user session.
`
`The Examiner respectfully disagrees with Patent owner. In response to Patent owner
`
`arguments against the references individually, one cannot show nonobviousness by attacking
`
`references individually where the rejections ·are based on combinations of references. See In re
`
`Keller, 642 F.2d 413,208 USPQ 871 (CCPA 1981); In re'Merck & Co., 800 F.2d 1091, 231
`
`USPQ 375 (Fed. Cir. 1986).
`
`Panasonic-1012
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`

`

`Application/Control Number: 95/002,035 and 90/012,342
`Art Unit: 3992
`
`Page 39
`
`(I)
`
`Patent owner argues that Coss is not "new art" and this Reexamination based on Coss as
`
`"new art" was improvidently grant and should be withdrawn.
`
`In response, the Examiner notes that "neither the patent owner nor the third party
`
`requester has a right to petition, or request reconsideration of, a finding that the prior art patents
`
`or printed publications raise a substantial new question." See MPEP 2646 (II)
`
`(2)
`
`Patent owner argues that Coss does not teach, disclose or suggest an authentication server
`
`that generates a user specific individualized rule set in response to a user ID as required by all the
`
`claims of the '1118 patent.
`
`However, the claims do not recite generating a user specific individualized rule set.
`
`Hence, in response to Patent owner argument that the references fail to show certain features of
`
`the invention, it is noted that the features upon which Patent owner relies (i.e., an authentication
`
`server that generates a user specific individualized rule set in response to a user ID) are not
`
`recited in the rejected claim(s). Although the claims are interpreted in light of the specification,
`
`limitations from the specification are not read into the claims. See In re Van Geuns, 988
`
`F.2d 1181, 26 USPQ2d 1057 (Fed. Cir. 1993).
`
`(3)
`
`Patentee asserts that Coss does not teach, suggest or disclose a rule set consisting of
`
`elements or conditions as defined and claimed in the '118 patent.
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`However, the Examiner respectfully disagrees. The specification describes the rule sets
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`at col. 4, lines 41-49 as follows:
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`Application/Control Number: 95/002,035 and 90/012,342
`Art Unit: 3992
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`Page 40
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`The rule sets specify elements or conditions about the user's session. Rule sets may
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`contain data about a type of service which may or may not be accessed, a location, which may or
`
`may not be accessed, how long to keep the rule set active, under what condition the rule set
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`should be removed, when and how to modify the rule set during a session.
`
`Coss teaches dynamic rules are rules which are included with the access rules as a need
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`arises. These rules can be loaded at any time to authorize specific network sessions. See col. 8,
`
`lines 24-36. The rules of Coss authorizes specific network session, which is the same as "type of
`
`service which may or may not be accessed, a location, which may or may not be accessed."
`
`( 4)
`
`Patent owner argues that Coss does not teach, suggest or disclose a redirection server into
`
`which a different rule set is programmed for each individual user session. Also, it is asserted that
`
`the set of rules is not unique for an individual user or an individual session, nor is the rule set
`
`removed and replaced for different user and user session.
`
`In response to Patent owner arguments against the references individually, one cannot
`
`show nonobviousness by attacking references individually where the rejections are based on
`
`combinations ofreferences. See In re Keller, 642 F.2d 413,208 USPQ 871 (CCPA 1981); In re
`
`Merck& Co., 800 F.2d 1091, 231 USPQ 375 (Fed. Cir. 1986).
`
`The Office action states that Radia discloses filtering profiles that is associated with each
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`user (see col. 9, lines 46-59) and Coss teaches categorizing the rule set such as "host group
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`identifier or IP address", "destination host group identifier or IP address" (see col. 4, lines 39-
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`43).
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`Application/Control Number: 95/002,035 and 90/012,342
`Art Unit: 3992
`
`Page 41
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`In response to Patent owner argument that the references fail to show certain features of
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`the invention, it is noted that the features upon which Patent owner relies (i.e., the rule set
`
`removed and replaced for different user and user session) are not recited in the rejected claim(s).
`
`Although the claims are interpreted in light of the specification, limitations from the specification
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`are not read into the claims. See In re Van Geuns, 988 F.2d 1181, 26 USPQ2d 1057 (Fed. Cir.
`
`1993).
`
`(5)
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`Patent owner submits that no motivation to combine the Radia and Coss was provided.
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`However, the Examiner respectfully disagrees. The Office action states:
`
`Since each individual element and its function are shown in the prior art, albeit shown in
`
`separate references, the difference between the claimed subject matter and the prior art rests not
`
`on any individual element or function but in the very combination itself-that is in the substation
`
`of the firewall 211 of Coss for the router 106 in Fig. 1 of Radia. Thus, the simple substitution of
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`one known element (i.e. firewall 211 for the router 106) for another producing a predictable
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`result renders the claim obvious.
`
`( 6)
`
`Patentee argues that Coss does not teach or suggest a redirection server programmed with
`
`a user's rule set or one correlated with a temporarily assigned network address.
`
`However, the Examiner respectfully disagrees. Coss teaches dynamic rules are rules
`
`which are included with the access rules as a need arises. These rules can be loaded at any time
`
`to authorize specific network sessions. See col. 8, lines 24-36. The rules of Coss authorizes
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`Application/Control Number: 95/002,035 and 90/012,342
`Art Unit: 3992
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`Page 42 _
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`specific network session, which is the same as "type of service which may or may not be
`
`accessed, a location, which may or may not be accessed."
`
`As per Coss not teaching a temporarily assigned network address, the Office action states
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`at page 340 and 341 of Request that that Coss does not teach the rule set being correlated to a
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`temporarily assigned network address, but that this is an obvious over Admitted Prior art
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`Specially, pages 340 and 341 stated the following:
`
`Cosset al. do not explicitly disclose the firewall 211 is programmed with a user's rule set
`correlated to a temporarily assigned network address.
`
`"In prior art systems as shown in FIG. 1 when an Internet user establishes a connection with an
`Internet Service Provider (ISP), the user first makes a physical connection between their
`computer 100 and a dial-up networking server 102, the user provides to the dial-up networking
`server their user
`
`ID and password. The dial-up networking server then passes the user ID and password, alone
`with a temporary Internet Protocol OP) address for use by the user to the ISP's authentication and
`accounting server 104. A detailed description of the IP communications protocol is discussed in
`Internetworking with TCP/IP, 3rd ed., Douglas Comer, Prentice Hall, 1995, which is fully
`incorporated herein by reference. The authentication and accounting server, upon verification of
`the user ID and password using a database 106 would send an authorization message to the dial(cid:173)
`up networking server 102 to allow the user to use the temporary IP address assigned to that user
`by the dial-up networking server and then logs the connection and assigned IP address. For the
`duration of that session, whenever the user would make a request to the Internet 110 via a
`gateway 108, the end user would be identified by the temporarily assigned IP address." [" 118
`patent, 1st paragraph of Background of the Invention section, emphasis added]
`Firewall 211 is programmed with a user's rule set correlated to an IP address. It would h